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Summary of Public Comments - Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor EA practice—is not allowed in wilderness areas. The Forest Service fails to explain how LWD removal will be prevented if boating is allowed in additional sections of the River. Even with a stated goal in the EA of adopting uniform rules for LWD across the three National Forests, there is no monitoring or implementation mentioned, making the proposal essentially and administratively unworkable. The ecology of stream habitat is greatly improved by the existence of LWD and streamside vegetation. Unfortunately, in order to accommodate boating these elements that are so critical to the ecology of headwater streams are often destroyed and sometimes removed to allow boat passage. In 2008, the Nantahala Forest Service was even petitioned by paddlers to remove woody debris on the Cheoah in order to improve “boater safety” after claiming no improvements were required during the NEPA review. Visitor safety may trump habitat concerns in the Forest Service manual, which would enable the Forest Service to diminish trout habitat. However, by not granting access to boaters now, the Forest Service would be protecting this critical habitat without having to injure boaters and instigate lawsuits. The indirect affect to habitat if boating were allowed must be considered in this EA, and under WSR statutes, primary emphasis must be given to protecting habitat and fauna before accommodating recreational boating (Ltr# 166, Cmt# 25) Subconcern # D I #42- Biologically, LWD is critical to the health of the river system and its aquatic and semi aquatic species. Without more resources to enforce this component of the management plan, it is our opinion that that LWD removal will more than likely occur as boaters will invariably remove it to achieve desired paddling destinations. This removal would not be a viable or acceptable and will have adverse impacts on the overall aquatic health of the ecosystem. Removal of woody debris in order to make way for boaters could damage viable systems of ecological importance. LWD recruitment and retention in the Wild and Scenic corridor should be standardized regardless of the National Forest. (Ltr# 193, Cmt# 36) Subconcern # E I #248- There is no adequate rule provided or proposed for recruiting the vast amount of large woody debris that will be accumulating in the river as more and more native eastern hemlocks fall into this river. The geologic nature of this reach, where narrow vertical gorges such as the “Alley” will act as bottlenecks, is where rapids will certainly be clogged with strainers in coming years due to the massive die-off of the hemlock trees. This is not to imply that challenge and risk should not be allowed as an accepted and integral part of an extreme sport that has its place in wild reaches. However, it is simply an important factor in a decision to permit a use that will soon be unmanageable. If whitewater boating is allowed in Chattooga Cliffs reach, there will undoubtedly be both biological damage from portages and inevitably search and recovery operations that will cause unacceptable damage to the area. (Ltr# 193, Cmt# 239) Subconcern # F #438- The USFS has found that The Upper Chattooga (where wood has never been managed by paddlers) has 4,171 pieces of wood and only 2 wood-related portages. Therefore only 0.02% of wood is potentially a recreational issue. The USFS has generated - and in the EA ignored - conclusive data that shows boating would have no impact on wood in the Chattooga River (Ltr# 193, Cmt# 426) Subconcern # F-H The EA fails to clearly state that wood is a non-issue. The EA once again dwells on the fact that there is wood in the Chattooga River and its tributaries as a rationale for imposing paddling limits. The EA proposes to prohibit wood removal which makes wood a moot issue. Wood has little or no ecological value in high gradient bedrock and boulder controlled reaches which makes wood a moot issue. The paddling and wood studies proved that only 1-5 out of several thousand pieces of wood in the river were a problem for paddlers which makes wood a moot issue. The EA on page 154 acknowledges that some wood removal is acceptable which makes wood a moot issue. Wood portages are temporary in high gradient streams due to wood mobility, which makes portage trails around wood a moot issue. Portages during the boating test study were conducted on bedrock which makes wood a moot issue. The EA documents that non-paddlers also remove wood but proposes no limits on non-paddlers making the EA inequitable in its treatment of the issue. The EA claims the value of wood is its benefit to brook trout, yet managers allow significant direct harvest of brook trout, and the USFS has admittedly nearly wiped the species out through the ongoing stocking of non-native trout. Limiting a use based on a miniscule and undocumented effect on brook trout while wiping the species out to benefit another use is not equitable and is arbitrary. (Ltr# 168, Cmt# 37) Subconcern # G 72
Summary of Public Comments - Managing Recreation Uses in the Upper Segment of the Chattooga Wild and Scenic River Corridor EA #97- They move woody debris and rearrange the riverbed to make the habitat for the stocked fish more attractive. Seems moving woody debris should be the same in either case. (Ltr# 193, Cmt# 90) Subconcern # G #206- If hiking trails are cleared of fallen trees, then why not water trails where needed?? (Ltr# 193, Cmt# 198) Subconcern # G #437- Throughout the EA, "LWD," standing for "Large Woody Debris" is found 93 times. Pages upon pages are devoted to LWD. Yet, every alternative proposes to allow removal of LWD only in limited cases, and never for boating. Based on this decision - LWD is a non-issue. Still the EA considers the impacts that "unauthorized removal" of wood might have. They do not at the same time consider the impact of unauthorized removal of fish, damage to rare species, camping, trail creation, ATV use, or other recreational misdeeds. The USFS selects only boaters as presumed rule-breakers. This is unfair, inequitable, biased, and indefensible. We hereby incorporate those comments as part of our comments on the EA. We have found absolutely no justification for limiting boating based on LWD - and neither has the USFS. (Ltr# 193, Cmt# 425) Subconcern # G #439- To limit boating based on concerns about unauthorized removal of LWD is not justified and to do so would be arbitrary and capricious, just as would be the banning of all angling because some anglers might fish without a license. Furthermore, wood removal was shown in the Inventory of Large Wood in the Upper Chattooga River Watershed to be carried out by nonboaters on the Upper Chattooga a logical conclusion because boating has been banned. Thus, any decision to ban or limit boating based on concerns about unauthorized removal of LWD by boaters without banning or limiting other uses known to remove LWD would be inequitable. (Ltr# 193, Cmt# 427) Subconcern # I #180- The Friends strongly urge the agency to adopt uniform standards for all three forests regarding policy enforcement and large woody debris (“LWD”) management. The removal of any LWD should be based on the “primary emphasis” standards found within section 10 of the Wild and Scenic Rivers Act. (Ltr# 193, Cmt# 172) Subconcern # I #524- I believe the LWD recruitment and retention in the W&S corridor should be standardized regardless of the National Forest and should also be consistent with the corridor prescription: It should not matter whether LWD is nearest the GA bank or the SC bank.12. COMMENT: I also believe LWD management for the Chattooga Cliffs “Wild” segment (entirely in NC) and the LWD management for the West Fork/Overflow “Wild” segment (entirely in GA) must be identical, including protective enforcement. (Ltr# 193, Cmt# 511) Public Concern 22 The Forest Service should reconsider the effects from boating on fisheries habitat and emphasize protecting and/or enhancing it (all comments from 2009 EA comment period). Response to PC 22 In Section 3.2.2A, Aquatics the impacts from boating on Aquatic Species and Habitat are discussed. Changes in recreational use on the Chattooga Wild and Scenic River (WSR) have the potential to impact aquatic, as well as terrestrial, habitats. The impacts to plants, terrestrial wildlife, and fisheries by each alternative are discussed in Section 3.2.2 Biology ORV. All potential scenarios and activities, such as creation of new portage trails, which may affect shoreline and the streambed, were discussed in this analysis. Section 3.4.2 Water and Riparian Corridor discusses environmental impacts to the riparian portion of these resources by alternative. Consultation with FWS is part of the process and impacts to T&E species are 73
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